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Information Shared by Tony Burfield of www.cropwatch.org
Referring to standard trade Certificates of Naturalness for Essential
Oils might be useful here. The wording I use to certify essential
oils for the trade as natural in my professional capacity usually
goes something along these lines...(this may not be the latest version
but it will serve to illustrate the point):
"Whatever Oil from Whatever country ....(fill in as appropriate)....
Meets the requirement for a flavour labelled natural under CFR 101.22(A)3
and meets the requirements of the natural flavour/natural flavouring
substances labelled in according with the regulations originally promulgated
under EEC Council Regulation No 88/388 dated 22.6.1988 Article 9.2,
and the subsequent amendments thereof. The product also meets the
conditions for fragrance ingredients, the definitions being set out
under ISO 9325 (1997) and so meets requirements for Natural Cosmetics
under guidelines proposed by the Committee of Experts on Cosmetic
Products 2000. The product or all the ingredients contained in the
product have been obtained by suitable physical processes, or enzymic
processes , or micro-biological processes or traditional processes
of food preparation from plant-derived or animal-derived raw materials."
There is a section on the naturalness certificate following the above
statement allowing for the percentage of any added ingredients to
be declared (i.e. anti-oxidants). For clarity I should also point
out that the term 'animal-derived raw materials' relates to commodities
such as insect products like 'lac' and not animal products such as
ambergris, civet, musk, castoreum etc. - which I will not deal with
on moral & ethical grounds.
The ISO 9325 (1997) Aromatic Raw Materials - Vocabulary provides various
definitions of essential oils under section 3.1 Essential oils; 3.2
Essential oils obtained without significant changes to composition
(e.g. rectified oils); 3.3 Essential oils obtained with significant
changes to composition (e.g. folded essential oils). Both Brian Lawrence
and myself are on record as disagreeing with ISO that dry-distilled
essential oils (defined under section 3.3.5 above) are in fact essential
oils at all - but apart from that the document seems eminently commendable.
If the NIRC are having further difficulties - they probably relate
to deciding which are physical and which are chemical or physio-chemical
processes. Unfortunately in many casers the individual materials
have to be considered in a case by case basis. For example, most aromatherapists
now accept that the annual production volume of Sandalwood oil East
Indian (Santalum album) is only a fraction of its former output, due
to its threatened ecological status. Many have been using instead,
selected fractions of solvent extracted Australian sandalwood (Santalum
spicatum), which is often falsely marketed as an 'oil' (only one or
two small suppliers actually steam distil the wood to generate the
oil). I wouldn't say therefore that Australian sandalwood oil from
S. spicatum is usually 'natural' from the definitions above.
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